Report of oil & gas well abandonment and reclamation on
federal lands administered by BLM-Utah
March 14, 2015
Stan Olmstead
P.O. Box 403
Jonesborough TN 37659
stanolmstead@gmail.com
Plugging and reclamation
of non-producing energy wells
The reasons to return
non-productive well sites and other associated energy land disturbance
activities to near natural surface conditions are numerous, and implicate both
environmental and multiple use concerns. Plugging prevents potential spills, soil and
water contamination, and the release of volatile hydrocarbons. Reclamation prevents invasive weeds and
fugitive dust, provides new forage for wildlife and livestock, reduces soil
erosion, and allows for a more scenic setting for humans. Air and water quality are improved, erosion is
reduced, wildlife have forage and cover, livestock have more forage, radiant
energy is not released to the atmosphere, and carbon sequestering is greater.
By regulation (43 CFR
3162.3-4 Well Abandonment, Onshore Order and APD approval) the lease owner and
well operator know that once the well is no longer producing in paying
quantities that the well and its related infrastructure is to be plugged,
facilities and equipment removed, disturbed sites re-contoured, stored top soil
administered to the area and the site re-vegetated to near natural vegetation.
The Bureau deliberately instructs its employees (IM No. 2012 -181) to conduct
an idle-well review and data entry into the Automated Fluid Minerals Support
System to document wells past 7 years of non-production. This effort to professionally abandon wells is
required by regulation, improves multiple resource values, services the public
responsibly and is professional.
While working at the BLM
Vernal Field Office I, along with other BLM employees, developed concern over
the lack of priority placed on the plugging of non-producing energy wells and upon
conducting appropriate and final reclamation. From 1992 through 2012 at the BLM-Vernal Field
Office (VFO) a number of wells were idle in 1992 and these same wells were still
not producing in 2012. VFO management was not requiring the operator to plug
and reclaim these non-productive locations with the appropriate interest to
serve the American public. VFO management focused heavily on land use permitting,
specifically energy development to include the permitting of oil & gas
wells through their Application for Permit to Drill (APD) process. A large effort;
which included considerable time, energy, and expense was conducted in
inspecting and documenting idle wells for the appropriate plugging, facility
removal, and reclamation of disturbed areas.
However this effort was wasted, due to the lack of importance by office management
in providing direction, either by an assessment of penalties, bond confiscation
(43 CFR 3401.1 thru 3401.8) or lease cancellation (43 CFR3108.3).
As a result of my
concerns, I conducted several FOIA requests to learn more about the numbers of
unplugged, un-reclaimed wells in Utah.
This report summarizes my findings.
FOIA requests
This report is a summary of four FOIA requests showing the
number of wells as recorded by the Agency’s Automated Fluid Mineral Support
System (AFMSS). FOIA information was
received from the Vernal Field Office (November
2012), Moab Field Office (March 2013),
Price Field Office (April 2013) and an
inclusive FOIA request from the Utah State Office (February 2015). The State Office FOIA request was
submitted by Public Employees for Environmental Responsibility (PEER).
Scope. Each request
asked generally the same question. What were the number of non-producing
oil and gas wells that are within the authority of the land management office
that have not produced for more than ten years? The FOIA request sought the well name, lease
number, legal location, and company name of all wells that have not produced
for more than 10 years and had not been Plugged and abandoned (P&A). The
information was to include non-producing wells that are on federal, tribal and
other lands; where the land management office has authority for these
nonproducing wells and responsibility for monitoring and compliance in relation
to plugging, abandonment, and final reclamation oversight. The 10 years of
non-production was an arbitrary time; however by experience a more than
reasonable time.[1]
Process of obtaining
records. Each office
should have been able to prepare the report through AFMSS in a matter of hours,
print out in less than 100 pages, and organize the data for easy analysis and
without charge. The offices,
however, demonstrated varying degrees of cooperation. For example, the
State Office responded to PEER’s FOIA request in three months with poor and
inadequate information and it took four more months for the office to provide
improved data. The Office then sent 6
separate documents requiring time-consuming calculations to interpret the data.
Additionally, in each request the Bureau staff member conducting
the query provided somewhat different information and documents required
interpretation by the requester. In the Vernal FOIA the column for last
production date was titled: Idle Since;
Moab it was Status Date, Price was Last Produced Date and the State Office
it was Effective Date. It can only be assumed each office was using a
different column title for the same last production date (?).[2]
Findings
The following report is
my calculations of idle well numbers from each of the FOIA requests. This report assumes that all wells, classified
as Gas Shut-In (GSI), Oil Shut-In (OSI), Water Injection well Shut-In (WIWSI),
Temporary Abandoned (TA) and Abandoned (ABD), in a reasonable period of time in
non-paying quantities should be considered for plugging and reclamation. A well
is considered with complete final abandonment after a Final Abandonment Notice
(FAN) is approved and the well is then listed as Plugged & Abandoned
(P&A) in AFMSS.
Using an estimate four
acres for each well site and its related infrastructure, I calculated that, based
on the 2013 FOIA response from the three Field Offices, there were an estimated
2,888 acres of un-reclaimed land in
Utah for wells more than 10 years in non-production at that time.[3]
Based on the 2015 FOIA response from the
Utah State Office, there are currently an estimated 2,228 acres of un-reclaimed land in Utah for wells more than 10
years in non-production.
Vernal Field Office data 11/20/2012:
Note: The Vernal Field Office
reported 355 wells without production for 10 or more years (7/26/65 – 9/19/02)
BLM – 239 wells
USFS – 3 wells
FEE – 13 wells
BIA – 99 wells
State – 1 well
Un-reclaimed public lands for Vernal Field Office (2012): ~ 1420
acres.
Moab Field Office data 3/18/13:
Note: The Moab Field Office provided only federal
wells; the number of other land management agency wells overseen by BLM is not known.
TA – 69
(9/4/65
– 11/10/99)
GSI/OSI – 64 (3/22/61
– 9/1/02
ABD – 171 (no
status date?)
Un-reclaimed public lands for Moab Field Office (2013): ~ 1216
acres.
Price Field Office data 4/9/13:
Note: The Price Field Office
provided only federal wells; the number of other land management agency wells
overseen by BLM is not known.
TA, GSI, DSI, OSI – 16 wells
(7/27/53 – 11/6/01)
ABD – 47 wells (no last produced date?)
Un-reclaimed public lands for Price Field Office (2013): ~ 252
acres.
Utah State Office data 2/27/15:
All data received:
GSI/TA/OSI/Orphan/DSI; 250 – wells (7/27/53
– 10/01/13)
ABD; 1,067 - wells (4/30/79
– 1/15/15)
Moab 300 wells
Price 69 wells
Salt Lake 36 wells
Vernal 912 wells
Only well data 7 years and older:
769 wells
Moab
200 wells
Price
34 wells
Salt Lake 25 wells
Vernal
520 wells
Only well data 10 years and older:
557 wells
Moab 162 wells
Price 29 wells
Salt Lake 23 wells
Vernal 334 wells
Un-reclaimed public lands in Utah (2015): ~ 2228 acres.
Conclusion
In sum, it is clear that
there are thousands of acres of un-reclaimed public land in Utah, despite BLM’s
obligation to ensure the plugging and reclamation of oil and gas wells that
have not been producing in paying quantities for ten years. Professional land managers are obligated to
fulfill the public trust responsibility not only to authorize land use and
development for energy related resources but also naturalizing the public lands
for the citizens post energy use. This is part of the mission of the Bureau by
definition … to sustain the health,
diversity and productivity of public land for present and future generations.
[1]
It is known that energy operators do at times place a well into a
non-production status for short periods of time for multiple reasons. These
reasons can be technical, energy field management, or energy prices. However
there are procedures for Temporary Abandonment and Shut-In wells and by design
are to be short term. After five years
of not producing, especially during periods of high-energy prices the operator
should begin to consider and initiate legal and responsible plug and
abandonment procedures. The Bureau through its own Instruction Memorandum (IM
No. 2012 -181) identifies 7 years of
non-production for action by the land management office to assure that idle
wells are having oversight to assure abandonment and reclamation and to
actively inspect and document the need for plugging and abandonment. A 10-year period of non-production should be
more than reasonable for the energy operator to initiate and complete plugging
and reclamation of idle wells.
[2] In another irregularity, the
Vernal Office charged $433.46 for the November 2012 FOIA then revised that amount
to $72.00 after a formal objection. The
Moab Office requested no charge. The
Price Office charged $105.00, and the last FOIA to the Utah State Office by
PEER was not charged. This difference in billing demonstrates a lack of
consistency in applying FOIA’s mandates regarding fees.
[3]
Note: The Salt Lake Office was not FOIA’d at that time.
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